1. Introduction
MiCA regulates crypto and MiFID II regulates derivatives — but as soon as euros move, a third regime applies: European payment law. Exchanges that want to process SEPA payments themselves or hold EUR balances need a PSD2 or EMI licence. It is the least known licence, yet the most tangible one: it determines how fast and cheaply your euros move in and out of the platform.
2. What does PSD2 regulate?
PSD2 (Payment Services Directive 2) is the EU directive for payment services. Anyone executing payments for third parties — receiving, holding, transferring money — needs authorisation as a payment institution from a national supervisor (in the Netherlands: DNB). PSD2 imposes capital requirements, safeguarding of client money, strong customer authentication and incident reporting.
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3. What is an EMI (e-money institution)?
An e-money institution may additionally issue electronic money: a digital EUR balance you hold with the platform. Your EUR balance at an EMI-licensed exchange is legally e-money — with mandatory 1:1 backing, safeguarded at a bank or in safe assets, separated from company funds.
4. PSD2 vs EMI: the difference
| Payment institution (PSD2) | E-money institution (EMI) | |
|---|---|---|
| Process payments (SEPA in/out) | Yes | Yes |
| Issue and hold EUR balances | No | Yes |
| Safeguarding client money | Yes | Yes, incl. 1:1 e-money backing |
For an exchange that wants to offer you a permanent EUR balance, EMI is the logical route.
5. Why does an exchange need this?
MiCA covers crypto services, not moving fiat. An exchange without its own payment licence must outsource this to an external partner — an extra link, extra costs, and often slower or more limited EUR functionality.
6. With vs without an own licence: what you notice
With an own PSD2/EMI:
- Direct SEPA in/out, often free and fast
- A real EUR balance on the platform, safeguarded
- EUR usable as collateral
- One accountable party when things go wrong
Via an external partner:
- Deposits run through a third party (a different name on your bank statement)
- Sometimes higher costs or limits
- EUR often converted straight into stablecoins — with a spread (example ~0.11%)
- When things go wrong: two counters
7. Which exchanges hold a payment licence?
Only a handful of exchanges have the full stack in-house. In our comparison tables we show per exchange whether the EUR rails run under an own licence or via a partner. Data-driven block with the current status per exchange.
8. The three-licence stack: MiCA + MiFID II + PSD2/EMI
An exchange that wants to offer everything — spot, derivatives, stocks and smooth EUR rails — needs all three regimes:
| Licence | Covers | See |
|---|---|---|
| MiCA | Spot crypto, custody | What is a MiCA licence? |
| MiFID II | Perpetuals, tokenised stocks | What is a MiFID II licence? |
| PSD2 / EMI | Payments, EUR balances | this page |
Fewer than five exchanges in the EU hold all three. That is no coincidence: each licence carries its own capital requirements and 6-12 month timelines.
PSD2/EMI is the least-known of the three EU licence regimes, yet the one you feel most directly. An exchange with its own payment licence can offer direct, cheap and fast SEPA in and out plus a genuinely safeguarded EUR balance; without it, your euros run through a third party with extra cost, delay and counterparties. Fewer than five EU exchanges hold all three licences.
Frequently asked questions
Is my EUR balance covered by deposit insurance?
No. E-money falls outside deposit guarantee schemes (those apply to banks). Safeguarding does apply: 1:1 backing, segregated from company assets.
How do I check whether my exchange holds its own payment licence?
Check the register of the relevant supervisor (e.g. DNB or FCMC) for the legal entity name.
Why does my SEPA deposit go to a different company name?
Then payments run through an external payment partner — the exchange has no licence of its own.
Does converting USDC to EUR fall under PSD2?
The EUR side does. That is why exchanges with their own EMI often have sharper conversion costs.
